Wiki Telehealth for nutritionists

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How should nutritionists be billed for telephone or audio/video visits? 97802/97803 or E/M. We are getting conflicting information. MDM seems more difficult to extract on these resulting in lower levels, however the providers are spending 30-60 minutes with each patient which could be coded higher based on time. Any help would be appreciated!
 
Nutritionists are not eligible to bill E&M services per CMS rules. Other than physicians physicians, CMS will only reimburse E&M services performed by a NP, CNS, CNM or PA. See the Medicare Claims Processing Manual, Chapter 12, section 30.6.1. Nutritionists are not medical practitioners, so I believe that in most jurisdictions, it would be considered out of their scope or practice to perform an E&M service, and in the absence of a specific payer policy stating otherwise, it could likely be considered fraudulent to bill their services with any E&M code with the possible exception of 99211.
 
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Nutritionists are not eligible to bill E&M services per CMS rules. Other than physicians physicians, CMS will only reimburse E&M services performed by a NP, CNS, CNM or PA. See the Medicare Claims Processing Manual, Chapter 12, section 30.6.1. Nutritionists are not medical practitioners, so I believe that in most jurisdictions, it would be considered out of their scope or practice to perform an E&M service, and in the absence of a specific payer policy stating otherwise, it could likely be considered fraudulent to bill their services with any E&M code with the possible exception of 99211.

Thank you, under normal conditions we only use 97802/97803 for these services. We aren't clear on how to bill them as Telehealth. Would we use the same codes and add modifier 95/POS 02?
 
Thank you, under normal conditions we only use 97802/97803 for these services. We aren't clear on how to bill them as Telehealth. Would we use the same codes and add modifier 95/POS 02?

For CMS, under normal circumstances you would bill those codes as telehealth with POS 02 when the patient is located in a location that qualifies as an originating site. Under the waiver that is currently in effect for the public health emergency, there are no restrictions on the originating site, and CMS has instructed providers to "report the place of service (POS) code that would have been reported had the service been furnished in person" and the modifier 95 "should be applied to claim lines that describe services furnished via telehealth." So as I'm understanding this, you'd bill your practice's usual place of service (e.g. POS 11 if it is an office) but add the modifier 95 to show that it was telehealth in this particular instance.

Here's the reference for the information quoted above - see question #5:
 
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